Kristi Shortridge

Let's see if I can clarify, Company A acquires Company B in August 2022. Company B terminated the plan as of October 31, 2022. Both companies were part of a controlled group with the Parent Company C. Company A became a controlled group on September 1, 2021 and Company B became a controlled group on July 8, 2022. All 3 companies have their own separate plans at the time of the acquisition. I appreciate the help, this is not something you run into everyday!

Company A merges with Company B. Company A and Company B have 401(k) plans. Company B terminates their 401(k) plan. There are 5 employees total in company B, 2 of the 5 employees transfer into Company A's 401(k) plan but 3 of the employees take a cash distribution. There is also a parent company, and they want to be conservative and file VCP for the failure. How would you present this for correction under VCP? Any thoughts would be appreciated!